NTN is a community based network with a common aim to
reduce the chemical load on the environment and to promote
environmentally responsible technologies and management systems.

NTN aims to be a true network reflecting a diversity of approach
with a solidarity of purpose. NTN has interests in all aspects of
toxic chemical pollution including regulatory and assessment
issues. Over 300 groups and campaigners from across Australia as
well as representatives from NZ and South Pacific, have already
registered as network participants.

ENVIRONMENTAL RISK AND INDUSTRY :

THE COMMUNITY VIEW

Members of the National Toxics
Network, have been involved in the issue of risk assessment and
risk communication for over a decade. Over this time the 250
groups and campaigners in our network have had to deal with the
issues of risk assessment, perception and communication in many
arenas ranging from contaminated land, species protection to the
siting of industrial facilities. I present this paper from an
unashamedly community perspective.

To focus this talk I would like to start with a quote from the US
National Research Council 1989.

" To remain democratic, a society must find ways to put
specialised knowledge into the service of public choice and keep
it from becoming the basis of power for an elite."

In many cases, the community's perception of the risk assessment
process is far from positive. It is often perceived as a powerful
tool used by industry and government 'after the event' to dismiss
real community concerns. There is often little trust in either
the proponent or the process. There is little understanding of
the actual risk analysis and what there is, is coloured by a
basic resentment of yet another imposed risk, however small.
There is also anger at the difficulties the community experiences
in both accessing and understanding the full range of relevant
information and this is then compounded by a total mistrust of
the risk assessment's scientific 'experts'. For the community the
traditional view of science as a rational, value free, objective
and a socially neutral search for truth has been seriously
undermined in recent years. The highly political debate
surrounding the nuclear industry has left the bulk of the
community confused and unwilling to readily accept the word of
science.

So how do we move forward ? As community groups we are aware that
risk assessment in some form is here to stay and we are also
aware that without concerted action on all sides, the debate will
not progress, the situation will remain adversarial and we will
not reach the 'socially equitable negotiated agreement' that must
be the basis for any effective risk management and mitigation.

To understand the breadth of community concerns, it is worthwhile
examining some of the preconceptions and broad assumptions that
underpin the risk assessment and communication process. This may
suggest some ways forward.

The Lay / The Expert

The concept of the 'expert' in the
risk assessment process particularly EIA has inspired hostility
and mistrust. Despite statements about regulatory environmental
toxicology now being multidisciplinary, in our experience, the
expert in risk assessment process that the community meet, are
usually discipline specific, from outside the area which they are
studying and employed by government or business. For the
community this perception of the 'expert' is strongly coloured by
concerns of 'conflict of interest', put bluntly, the community
always asks, "Who pays the expert?"

Even when experts are drawn from the regulatory agencies, there
is mistrust as community groups have watched regulatory 'experts'
criss cross the professional ladder, from government to industry
and back again. This is particularly so in the area of
toxicology. The mistrust is further compounded by the utilisation
of 'experts' from overseas at substantial cost and who can return
there after their job is done.

At the same time 'lay knowledge' is usually dismissed, ignored
and in the worst cases, ridiculed. Fortunately in more recent
times, the growth in community monitoring has done much to return
credibility to 'lay knowledge' and at least in the case of Koori
groups, there has been some recognition by government and
industry of the deep understanding of the lay community who know
their 'backyard' intimately.

So often, I have seen valuable community generated data, surveys
and advice ignored in an assessment process only to be validated
years later. In the area of toxicology it has constantly been the
general community who have alerted authorities to health and
environmental impacts of chemical agents.

The terms 'expert' and 'lay' do little to assist the risk
assessment debate and I would suggest that we accept a
'continuum' of knowledge and information in assessing risks, from
the scientific to the experience based. This would provide not
only access to a much wider range of relevant data but would go a
long way in building a sense of community involvement and
ownership in the process.

Those that have power / Those who do not .

The issue of 'lay' versus 'expert' is closely tied to the issue
of power and control and these must also be addressed in a
socio-economic framework.

Risks are often accepted as being inevitable due to financial
constraints such as employment or the inability to buy a house in
less polluted area or on a macro level, the inability to change
world events,(eg., French nuclear testing.) Acceptance of risk in
this framework is far from a success for risk communication,
rather a response to disempowerment.

I have lost count of the number of times that government or
industry reps frustrated at the repeated concerns of the
community have responded with, "Well if you don't like it,
why don't you move!" Although said in the heat of the
moment, the underlying assumption is that people always have a
choice. Despite the political rhetoric, it is well to remember
many Australians do not have the economic freedom to choose where
they live or work. Only recently at an air quality seminar held
by EPA, a researcher responded to a question about air standards
with the comment, that if people were silly enough to live in the
CBD and then choose to work there, of course, their exposure to
air toxics would be above acceptable limits. A true enough
statement ? Or one that failed to understand that risk assessment
must fully take into account social equity.

But power and control for the community are also linked to
education, computer skills and the ability to understand the real
'nitty gritty' of risk analysis. The complaint so often heard is
that the community is emotional and unable to grasp complex
concepts particularly in relation to statistics yet are still
unwilling to accept on face value the word of government or the
RA proponent.

What has always surprised me is that at an international level,
we accept that we must 'capacity build' and transfer technology
to our developing neighbours, yet, we do not offer our own
community the same privilege. If we wish an informed debate on
risk analysis then we must put some effort into capacity building
our own community. This is not 'pie in sky' stuff, the US
provides community groups with access to software and expertise,
why can't Australia.

Power also influences the notion of acceptability and while the
preferred approach to risk communication is a 'dialogue
reflecting a mix of interests, knowledge and values prevailing in
the community' (Gay&Heath,'94), this is rare, and what
usually occurs was well put by Fiscchoff's, when he said
"each definition of risk makes a distinct political
statement regarding what society should value" (Fischhoff,
'85). It is often it is those in power and in influential
position who define what is of value and subsequently what is
then considered 'acceptable risk'.

Those who have information /
Those who don't.

Closely related to the issue of
power is the problem of community access to data and relevant
information. Community restrictions to information can be caused
by a variety of factors but the ones that prompt the most hostile
response are the claims by industry and government of 'Commercial
in Confidence' and the government policy of cost recovery in
regards to spatial data. This point was illustrated in the recent
community involvement in the Deferred Forest Assessment procedure
(an environmental risk assessment process for future logging
verses reserve status.) This process clearly highlighted the
inequitable access to the electronic data and basemaps that were
essential for community groups to participate equally in the risk
assessment process. Similarly, the continual claims for
commercial confidence in regards to chemical products, analytical
testing standards, factory storage and processes places the
community at a distinct disadvantage.

While we hear much about community as equal stakeholders in the
RA process until they are provided with equal access to data and
relevant information, this remains pure rhetoric. We also
consider legislated 'community right to know' is a prerequisite
for successful participation in the risk assessment process.

The issue of data access is complicated by the lack of quality
data for the Australian context. If one accepts Scala's
definition of "risk assessment in toxicology as a process
whereby relevant biological, dose response and exposure data are
combined to produce a qualitative or quantitative estimate of
adverse outcomes ", then Australia is significantly 'behind
the eight ball'. While we may have biological or hazard
assessment data that is relevant, ambient levels, human exposure
data or specific information on dose responses for our native
wildlife is sadly lacking.

As was recently made pertinently clear in a the Regulatory Impact
Assessment for the PCB Management Plan (National Advisory Body on
Scheduled Waste 95), [RIA are a legislatively required
cost/benefit assessments for modifications and new Acts.] ,
Australia still does not have the basic data on contaminants in
the environment nor does it have exposure data for its human and
wildlife population.

The discussion of data acquisition is often described in risk
perception terms of involvement, uncertainty and desire to exert
control, yet experience had shown us that despite the motivation
for information acquisition, a key element in any successful
community participation in risk assessment programs is the
provision of easily understood and accessible information.

In 1993 after much lobbying, the NSW Regional Agriculture
sponsored our research group to create the Dipsite Community
Access Information System.

The issues relating to the assessment, management, remediation
and liability of over 1600 contaminated cattle dip sites (DDT,
Arsenic) in Northern NSW, required a well informed public that
both understood the issues and felt some involvement in the
management of the problem. This required access to information on
site history, the toxicity of the contaminants and current
chemicals involved, exposure pathways and the environments at
risk. The information repository concept had already proven to be
an essential component in USEPA conflict resolution over polluted
sites.

In the case of the cattle dipsites, the provision of accurate up
to date information not only promoted informed decision-making on
behalf of the community, it facilitated community involvement and
ownership of the contaminated sites affecting their area. Armed
with accessible information, community groups such as Landcare
became actively involved in managing the sites and the mitigation
of environmental damage. For the affected residents, the
information system provided the main source of much of the
relevant information including the results of sampling of their
backyard .

Those who take the risk / Those
who gain the benefit

There is an inherent unfairness in
the risk assessment process that is often subjugated or explained
away by arguing general benefits to the community, "We all
need development." etc., but in reality it is often those
that take the risk and pay the cost that do not gain a direct
benefit. Nowhere is this more obvious than in the management of
contaminated land. While it may be an industry that polluted the
land in the process of making profits, it is often an unrelated
community who must live on the land, assess the risks and in some
case even pay the costs of cleanup. At the very least, financial
security is lost due to chemical contamination and the resident
is left to deal with stress and disempowerment.

While the much touted Polluter Pays Principle is just that, a
principle with no legislative backing, risk assessment must
address the issues of liability. It would be naive of us not to
acknowledge the use of the risk assessment process in the
political and commercial estimates of costs and benefits and the
justification of actions or more often no action.

Nowhere was this more obvious than in the review of standards for
DDT and Arsenic in soil. Literally residents living on
contaminated sites went to bed one night with an investigation
level for Arsenic of 30ppm in soil and woke up to a new level of
100ppm. Soon after the investigation level for DDT was raised
from around 1ppm to 50ppm. The ramifications for buy-out,
compensation and health concerns were immense yet there were no
real attempts at community involvement in these risk assessment.

The well rehearsed argument that the community in general
benefited from the industry's products often rings hollow,
particularly in the case of chemical agents. The consideration of
whether a society needed these particular products, never
involved the community in the first place nor does it today.

In the assessment of the risk so often the only clearly
recognised end point is death. The issue of quality of life and
ongoing good health can be ignored. Yet there is no doubt that
asthma and is on the rise and the incidence of some cancers have
increased substantially.

NTN works with a action parent group in a NSW rural town. The
children involved carry 'body load' of nonmethanic hydrocarbons
such as benzene, toluene as well as chlorinated solvents and
organochlorine compounds. The children appear to have ongoing
health problems and are constantly in and out of hospital. Over
the last 6 years the parents have called for air monitoring and
health investigations. After years of lobbying the Regional
Health Department carried out air monitoring for a particular
pesticide. It did not monitor for the hydrocarbons of concern but
it did detect chemicals used for termite control. The chosen
pesticide which was looked for was not detected (and probably
could not have been due to the sampling equipment) yet assurances
were given that all was well. To this day no one has seriously
investigated a connection between these children's illnesses and
the contaminants they carry their small bodies.

For those suffering environmental health problems, risk
assessment provides little comfort. I have never seen data on
existing chemical body load factored into a risk analysis nor
have I seen chemical sensitivities particularly in children built
in to equation. In the case of environmental health, risk
assessment is a blunt tool !

'Old Luggage' vs 'New Broom'
debate

The role of trust in risk
perception and communication should never be underestimated. So
often I have heard the comment from regulators and industry,
"Why don't you trust us ?" Yet, NTN's database is full
of incidences highlighting misinformation and misrepresentation
of products, secrecy regarding processes, the withholding of data
and the list goes on. Most importantly, when the assessments of
the past are proven to be wrong, the only response is the excuse
of 'old science'.

This brings us to the jargon of 'old luggage versus new broom'.
There is no doubt that the community brings with it our old
luggage of mistrust and suspicion based on years of experience.
The response by legislators and industry is but "we're a new
broom, we'll run a transparent open process, full of meaningful
consultation and information distribution". Yet community
groups have heard this all before and so it will take a great
deal of significant action to demonstrate that the game has
really changed.

To change things around and build the good faith that is
essential to the RA process, it will require a review of many of
the old decisions made in secrecy and isolation that are still
affecting people today. It will also require a cultural change in
attitude where community knowledge is valued and incorporated
into the decision making process. Most importantly, equal access
to the data and relevant information will have to be assured for
community stakeholders and industry and government will have to
stop hiding behind commercial in confidence claims. The community
will need resources to 'capacity build' those who wish to be
equal players in the game. Further requirements will include an
accessible decision audit as part of the publicly accessible
information system to ensure community trust in the 'open
transparent process' and there is a need for guaranteed provision
for follow up monitoring and feed back to check the original risk
assessment.

Certainly, the recent consumer response to the risk from mad cow
disease in UK has illustrated the strength of community outrage
and its refusal in this situation to accept any risk whatsoever.
The issue of what defines "acceptable risk" is as
topical today as it was a decade ago. I'm sure the figures for
contracting Creutzfeldt-Jacob Disease would be well within the
most stringent formal definition of 'acceptable risk' yet once
aware of the possibility of hazard from consuming affected beef,
the general population considered that the only 'acceptable' risk
was no risk.

References :

ACA. (1995) Australian Academy of
Science Fenner Conference on the Environment. Risk and
Uncertainty in Environmental Management, Background Papers.'